State of California et al v. Trump et al

Filing 38

MOTION to Relate Case Pursuant to N.D. Cal. Civ. L.R. 3-12(b) filed by Sierra Club, Southern Border Communities Coalition. (Attachments: #1 Declaration of Cecillia D. Wang, #2 Exhibit A to Declaration of Cecillia D. Wang, #3 Exhibit B to Declaration of Cecillia D. Wang, #4 Proposed Order, #5 Certificate/Proof of Service)(Wang, Cecillia) (Filed on 2/26/2019)

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DROR LADIN*
NOOR ZAFAR**
HINA SHAMSI*
OMAR C. JADWAT*
AMERICAN CIVIL LIBERTIES UNION FOUNDATION
125 Broad Street, 18th Floor
New York, NY 10004
Tel: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
*Admitted pro hac vice
**Application for admission pro hac vice pending
CECILLIA D. WANG (SBN 187782)
AMERICAN CIVIL LIBERTIES UNION FOUNDATION
39 Drumm Street
San Francisco, CA 94111
Tel: [phone]
[e-mail]
SANJAY NARAYAN (SBN 183227)***
GLORIA D. SMITH (SBN 200824)***
SIERRA CLUB ENVIRONMENTAL LAW PROGRAM
2101 Webster Street, Suite 1300
Oakland, CA 94612
Tel: [phone]
[e-mail]
[e-mail]
***Counsel for SIERRA CLUB
Attorneys for non-parties SIERRA CLUB and SOUTHERN
BORDER COMMUNITIES COALITION (additional counsel listed on following page)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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STATE OF CALIFORNIA, et al.,
Plaintiffs,

Case No.: 4:19-cv-00872-HSG

v.
DONALD J. TRUMP, in his official capacity as
President of the United States of America, et al.,
Defendants.

DECLARATION OF CECILLIA D.
WANG IN SUPPORT OF
ADMINISTRATIVE MOTION TO
CONSIDER WHETHER CASES
SHOULD BE RELATED

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DECLARATION OF CECILLIA D. WANG IN SUPPORT OF ADMINISTRATIVE MOTION
TO CONSIDER WHETHER CASES SHOULD BE RELATED
CASE NO: 4:19-cv-00872-HSG

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Additional counsel for non-parties Sierra Club and Southern
Border Communities Coalition:
MOLLIE M. LEE (SBN 251404)
CHRISTINE P. SUN (SBN 218701)
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION OF NORTHERN CALIFORNIA, INC.
39 Drumm Street
San Francisco, CA 94111
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
DAVID DONATTI*
ANDRE I. SEGURA (SBN 247681)
AMERICAN CIVIL LIBERTIES UNION FOUNDATION
OF TEXAS
P.O. Box 8306
Houston, TX 77288
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
*Admitted pro hac vice

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DECLARATION OF CECILLIA D. WANG IN SUPPORT OF ADMINISTRATIVE MOTION
TO CONSIDER WHETHER CASES SHOULD BE RELATED
CASE NO: 4:19-cv-00872-HSG

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I, Cecillia D. Wang, declare and state as follows:

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1.

I am an attorney licensed to practice law in the State of California and an attorney for

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Sierra Club and Southern Border Communities Coalition, the Plaintiffs in the action Sierra Club et

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al. v. Trump et al., No. 4:19-cv-00892-KAW. I have personal knowledge of the facts stated herein

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and, if called as a witness, I would testify competently thereto.

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2.

Whether Cases Should Be Related.

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I file this Declaration in support of the attached Administrative Motion to Consider

3.

Defendants in Sierra Club et al v. Trump et al, No. 4:19-cv-00892-KAW, have not

yet appeared in that case. Accordingly, Sierra Club and Southern Border Communities Coalition are

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unable to obtain their views on the Administrative Motion to Consider Whether Cases Should Be

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Related pursuant to Civil Local Rule 7-12.

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4.

action, Sierra Club et al. v. Trump et al., Case No. 4:19-cv-00892-KAW.

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Attached hereto as Exhibit A is a true and correct copy of the complaint in this

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Attached hereto as Exhibit B is a true and correct copy of the complaint filed in State

of California et al. v. Trump et al., Case No. 4:19-cv-00872-HSG.

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I declare under penalty of perjury under the laws of the United States that the foregoing is

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true and correct and that this declaration was executed on February 26, 2019, at New York, New

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York.

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/s/ Cecillia D. Wang

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DECLARATION OF CECILLIA D. WANG IN SUPPORT OF ADMINISTRATIVE MOTION
TO CONSIDER WHETHER CASES SHOULD BE RELATED
CASE NO: 4:19-cv-00872-HSG